U.S. Customs and Border Protection (CBP) recently issued guidance via the Cargo Systems Messaging Service (CSMS) on filing entries for imports from Canada subject to duties under Section 338 of the Tariff Act of 1930 (Section 338). We previously covered President Trump’s imposition and subsequent modification of these Section 338 tariffs here, here, and here.
From Settlements to Strategy: The Fraud Division’s Trade Enforcement Priority and What It Means for Importers
On September 1, we posted on the Government Enforcement, Compliance & Investigations Report about how a Taiwan-based LED manufacturer and its U.S. subsidiary agreed to pay $5.15 million to resolve False Claims Act allegations that they evaded Section 301 tariffs by transshipping Chinese-origin LEDs through Taiwan. The settlement, announced August 5, 2026 by the U.S. Attorney’s
CBP Announces Increased Enforcement and Verification of Importer of Record Numbers
U.S. Customs and Border Protection (“CBP”) issued a Federal Register notice that it is now ready to execute “executing enhanced enforcement procedures.” CBP has indicated that it will start verifying importer of record information provided by each importer on CBP Form 5106, and importers of record have until September 18, 2026, to correct any errors
Tariffs for UK Origin Patented Pharmaceuticals Reduced from 10% to Zero
The Trump Administration has officially reduced tariffs on patented pharmaceuticals and associated pharmaceutical ingredients imported from the United Kingdom (UK) from 10% to 0%. This change, effective July 31, 2026, is the result of an agreement between the United States and the UK, which created a carve out for UK origin pharmaceutical products from the recent national security tariffs imposed on patented pharmaceuticals pursuant to Section 232 of the Trade Expansion Act of 1962 (Section 232).
BIS Proposes Expansion of Section 232 Metals Tariffs to Additional Derivative Products
On August 4, 2026 the Bureau of Industry and Security (BIS) published a notice seeking public comments on expanding tariffs applicable to certain steel, aluminum and copper derivative products under Section 232 of the Trade Expansion Act of 1962 (Section 232) to fourteen (14) additional derivative products.
The list of products proposed to be subject
Section 301 Forced Labor Tariffs Challenged Again—This Time by 25 State Attorney Generals
On August 3, 2026, the state attorney generals of twenty-five states (25) co-led by State of Oregon, Arizona and California filed a complaint in the Court of International Trade (CIT) challenging tariffs imposed under Section 301 of the Trade Act of 1974 (Section 301) to address forced labor. The complaint alleges that Section 301 forced labor tariffs are ultra vires, arbitrary, capricious and contrary to law.
This complaint by the 25 state attorney generals challenging the legality of the Section 301 forced labor tariffs, joins other lawsuits pending before the CIT that were filed by small business plaintiffs, Burlap and Barrel, Inc. and Collective Horology LLC.
President Trump Issues Proclamation Imposing Tariff-Rate Quota on Quartz Surface Products
On July 31, 2026, President Trump issued proclamation “To Facilitate Positive Adjustment to Competition From Imports of Quartz Surface Products,” introducing a tariff-rate quota (“TRQ”) that will go into effect on August 15, 2026 on imports of certain quartz surface products under Section 203 of the Trade Act. The action follows a recommendation from the International Trade Commission in May 2026, which found that increased import volumes of quartz are harming the domestic quartz industry.
USTR Imposes New Section 301 Tariffs Targeting Forced Labor Concerns Across 60 Economies
The Office of the United States Trade Representative (USTR) has announced the imposition of new Section 301 tariffs under the Trade Act of 1974. Following investigations into global forced labor policies, the USTR has determined that 60 economies have failed to adequately impose or enforce prohibitions on the importation of goods produced with forced labor. The tariffs take effect at 12:01 a.m. Eastern Time beginning July 24, 2026.
CBP Issues New Forced Labor Enforcement Operational Guidance for Importers
On June 12, 2026, U.S. Customs and Border Protection (“CBP”), through a Cargo Systems Messaging Service (CSMS) notice, issued a comprehensive new Forced Labor Enforcement Operational Guidance for importers.
USTR Opens Comment Period on Proposed U.S.-China “Board of Trade”
On June 2, 2026, the Office of the United States Trade Representative (“USTR”) announced a public comment period related to the development of a new government-to-government mechanism, a proposed U.S.-China “Board of Trade,” intended to provide an ongoing channel for managing aspects of bilateral trade between the United States and China.